From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] SDS missing ingredients
Date: Fri, 23 Feb 2018 12:57:18 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 161c3cfe9aa-6e9d-c7b2**At_Symbol_Here**

Oh my.  Your experience must be with chemicals supplied to chemical labs, because consumer products routinely leave off ingredients from SDS, and a lot of other data, too.  Check out the SDS requirement from OSHA.  They con't even require the 10 tests on section 11 to be reported either with data or the lack of testing.  They recommend it, but don't require it.

US SDSs are a mess.  I'm right now doing an evaluation of products for an art conservation project in a major museum.  Those SDSs, both US and Chinese are a disaster. I'm having to go to the same products distributed by Sigma Aldrich to get the straight poop.

AND NOW TO A BIG PROBLEM:  The only decent SDSs readily available in the U.S. are from Sigma Aldrich.  But this company is now, as I understand it, Milipore Sigma.  And those Milipore SDSs are NOT good.  If the Sigma Aldrich SDSs go a way, we are going to have to find a better source somewhere.    

Anyone else out there notice this?

Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062


-----Original Message-----
From: Hadden, Susan [JRDUS] [JRDUS] <SHADDEN**At_Symbol_Here**ITS.JNJ.COM>
Sent: Fri, Feb 23, 2018 10:06 am
Subject: [DCHAS-L] SDS missing ingredients

While investigating an incident at my site recently, I came across an interesting issue. Interested in your thoughts..
The material involved is a commercially available spray disinfecting cleaner.
The container label listed these ingredients:
Active ingredients:
N-alkyl dimethyl benzyl ammonium chloride, 0.1%
N-alkyl dimethyl ethyl benzyl ammonium chloride, 0.1%
Inert ingredients:  98%
I pulled the SDS to look for more exposure information. The SDS (updated June 2017) did not list those active ingredients but did list the propellants used and EDTA.  
This is what the SDS says:
Chemical Name                                                CAS number       %
Butane                                                                 106-97-8               1-5
Diethylene glycol monobutyl ether            112-34-5               1-5
Propane                                                               74-98-6                 1-5
EDTA                                                                     64-02-8                 1-5
Composition comments                US GHS: The exact percentage (concentration) of composition has been withheld as a trade secret in accordance with paragraph (i) of 1910.1200.
I took that statement to mean the exact percentage of the ingredients listed were withheld, not that there were other ingredients not listed. It says percentage, not components. Though if you do the math, clearly something is missing from this list.
I thought that rather odd so I called tech support of the manufacturer. At first, they were confused as well, then told me that because the active ingredients were EPA registered materials, they did not have to be listed on the SDS. My reaction: Say what???
I have seen SDS that said proprietary mixture but still gave you a clue. But I had no idea an SDS could give no indication that there were other ingredients. 
No one I have asked at my organization has ever heard of this.
Have any of you? 
No longer trusting SDS (which I suppose I should know better than to anyway).
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